Ranger v. Alamitos Bay Yacht Club

Summary

The court held that the 1984 amendments to the Longshore and Harbor Workers’ Compensation Act did not eliminate otherwise available general maritime negligence and unseaworthiness remedies for club employees excluded from the federal compensation scheme. It also held that California’s workers’ compensation exclusive-remedy provision cannot displace substantive federal maritime rights under the supremacy clause. The court reversed and remanded because the lower courts had not resolved whether Ranger’s claims otherwise satisfy admiralty jurisdiction or are barred by other provisions of federal law.